Responding to school closures

Privacy Disclosures for California Residents

This Privacy Notice for California Residents (“CA Notice”) supplements the Clever Privacy Policy
as well as any other agreement you may have with us. Any terms we use in this CA Notice that
aren’t defined will have the meaning we provide in the Privacy Policy or other agreements.

California law requires us to disclose certain information regarding the categories of personal
information we collect. For purposes of this CA Notice, “personal information” has the meaning
provided by the California Consumer Privacy Act (the “CCPA”) and does not include information
that is publicly available, that is deidentified or aggregated such that it is not capable of
being associated with us, or that is excluded from the CCPA’s scope, such as personal
information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA
or the Driver's Privacy Protection Act of 1994. This CA Notice does not apply to information
relating to our employees, contractors, or other personnel.

A note about Student Data. Clever provides the Services to Schools as a “School
Official” under FERPA. That means that we collect, retain, use and disclose Student Data only
for or on behalf of a School customer for the purposes of providing the Services specified in
our agreement with the School, and for no other commercial purpose. Under the CCPA, we collect,
retain, use and disclose Student Data as a service provider to our School customers and
this CA Notice does not describe our practices with regard to Student Data or any other
personal information we process as a service provider.
If you have a question or would like to exercise your California consumer rights to knowledge,
access or deletion, please contact your School directly.

Collection and use of personal information. We collect personal information
from and about you for a variety of purposes. For example, we use personal information to
respond to your requests, engage with you as a customer, developer or other vendor, and provide
our Services to you or receive Services from you; for marketing and advertising purposes; to
monitor, improve, and develop our products and Services; and to protect the security and
integrity of our business, comply with legal requirements and obligations; for our business and
operational purposes; and as otherwise permitted or required by law.

The type of personal information we collect will depend on how you engage with us (for example,
as a customer or potential customer, as a Developer, or as a website visitor). In the last 12
months, we have collected the following categories of personal information:

Identifiers, such as your name, address, phone number, email address, or other similar
identifiers;

California customer records, such as payment information;

Professional and educational information, if you apply for a job with us through our website;

Commercial information, such as a history of our Services purchased, obtained or considered;

Internet/Network information, such as device information, logs and analytics data;

Geolocation data, such as precise location data from your device or generated based on your IP
address; and

Inferences about your interests and preferences, generated from your use of our sites.

We collect this information directly from you, from our business partners and affiliates, from
your browser or device when you visit our websites, or from third parties that you permit to
share information with us.

Disclosure of Personal Information. We share personal information with third
parties for business purposes or we may sell your personal information to third parties, subject
to your right to opt out of those sales (see Your Rights and Choices below).
The categories of third parties to whom we disclose your personal information may include: (i)
our service providers and advisors, (ii) vendors who assist us with marketing and advertising
our services; (iii) analytics providers; (iv) third parties with your consent or at your
direction, or with whom you interact through our Service.

When we disclose your personal information to our service providers, vendors or other third
parties that process the information on our behalf, we have entered into a written contract that
includes terms substantially similar to this notice and we will remain liable for any breach of
this notice that is caused by the acts or omissions of our service providers.

We do not sell your personal information for monetary or other valuable consideration.

Your Rights and Choices. As a California resident, you may be able to request
to exercise the following rights:

The Right to Know any or all of the following information relating to your personal
information we have collected and disclosed in the last 12 months, upon verification of your
identity:

The specific pieces of personal information we have collected about you;

The categories of personal information we have collected about you;

The categories of sources of the personal information;

The categories of personal information that we have disclosed to third parties for a
business purpose, and the categories of recipients to whom this information was disclosed;

The categories of personal information we have sold and the categories of third parties to
whom the information was sold; and

The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion of personal information we have collected from you, subject to
certain exceptions.

The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However,
please note that if the exercise of these rights limits our ability to process personal
information (such as in the case of a deletion request), we may no longer be able to provide you
our products and services or engage with you in the same manner.

To Submit your California Consumer Rights Requests. You may submit a request to
exercise your California Consumer Rights through one of the mechanisms described below. We will
need to verify your identity before processing your request, which may require us to request
additional personal information from you or require you to log into your account, if you have
one. In certain circumstances, we may decline or limit your request, particularly where we are
unable to verify your identity or locate your information in our systems, or as permitted by
law.